G.1.28 MBL Ethics and Compliance Hotline Reporting Policy

Date: October 1, 2019

1.0 Policy Statement

The Marine Biological Laboratory (MBL) expects its employees to perform their duties and responsibilities in accordance with the MBL’s policies and procedures. The MBL provides various mechanisms to report concerns about suspected compliance issues.

The purpose of this policy is to reinforce the importance of adherence to the MBL’s policies and procedures and to encourage good faith reports of allegations of misconduct concerning compliance with MBL policies and procedures. MBL strictly prohibits retaliation against anyone who makes a such report in good faith.

2.0 Guidelines

1. MBL employees are expected to follow all MBL policies and procedures in carrying out their work duties and responsibilities.
2. An employee who has a question about the propriety of any practice under MBL policies and procedures should seek guidance from his/her supervisor, member of Senior Staff who has responsibility for overseeing compliance with the particular policy or procedure, or the Director of Human Resources.
3. An employee who becomes aware of a potential or actual material violation of MBL policies or procedures should report such potential or actual conduct, regardless of whether the employee is personally involved in the
4. An employee may request that such a report be handled as confidentially as possible under the circumstances, and the MBL will endeavor to handle all such reports with discretion and with due regard for the privacy of the reporting
5. An employee may make anonymous reports through the EthicsPoint hotline. However, any investigation may be hampered due to the inability to contact the employee to obtain a full and complete account of relevant and necessary facts, or to ask additional questions or seek clarification as any investigation
6. An employee who comes forward in good faith with reports or concerns about compliance with MBL policies or procedures shall not be subject to reprisal or retaliation for making such a report. Any employee who believes that he/she is being retaliated against for making such a report should immediately bring it to the attention of the Director of Human Resources for immediate investigation.

3.0 Points of Contact 

An employee is encouraged to make such a report to his/her immediate supervisor. If the employee feels unable to do so or if there is any reason why this may not be appropriate, the employee should raise the issue with the Director of Human Resources or the MBL office or official who has responsibility for overseeing compliance with the particular policy or procedure in accordance with the guidelines below. An employee who is unsure to whom he/she should make a report or address his/her concerns should consult with the Director of Human Resources, humanres@mbl.edu or the office listed below:

• In the event of any claim of financial misconduct or inappropriate expenditure(s) of funds (including all grant funds, federal, and non-federal), or any claim regarding questionable internal controls, accounting practices or auditing matters, the employee should follow the guidelines above, but should also make such a report to the Director of Finance.
• An employee with reports or concerns about the MBL’s employment policies and procedures (including such policies as G.1.2 Disciplinary Procedure, G.1.12 Drug and Alcohol Policy) should consult with the Director of Human
• An employee with reports or concerns about the MBL’s non-discrimination policy (A.2.4 Equal Opportunity, Affirmative Action and Diversity) should consult with the MBL’s Director of Human Resources.
• An employee with reports or concerns about sexual assault or unlawful discrimination and harassment (A.2.1 Unlawful Harassment) should consult with the Director of Human Resources.
• An employee with reports or concerns about conflict of interest (K.1.3 Conflict of Interest) should consult with his/her manager, department director, but, in the case of questions concerning supervisory personnel, the employee may also consult with the Director of Human Resources.
• An employee with reports or concerns about workplace safety issues should consult with the MBL’s Director of Facilities.
• An employee with reports or concerns about academic fraud or scientific research misconduct should consult with the Director of the Division of Research.
• An employee who is unsure to whom he/she should make a report or address his/her concerns should consult with the Director of Human Resources

Hotline

An employee should report concerns as discussed above. However, if he/she is concerned about doing so, the employee may file a report with EthicsPoint — an independent ethics and compliance hotline contracted by the MBL. Calls to EthicsPoint made within the U.S. may be placed by dialing 877-534-0367. Reports can also be filed online at: https://mbl.ethicspoint.com. EthicsPoint provides an alternative way to report activities which may involve misconduct or violations of MBL policy confidentially. This service is not a substitute for, nor does it supersede, any existing reporting methods or protocols already in place at the MBL for reporting suspected problems or complaints. Any suspected problems or complaints reported via EthicsPoint will be reviewed in accordance with current MBL policies and procedures.

Employees represented by a bargaining unit may be governed by the appropriate bargaining unit agreement.